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TMI BlogAdvance Pricing Agreement - Section 92CCX X X X Extracts X X X X X X X X Extracts X X X X ..... . The APA offers better assurance on transfer pricing methods and are conducive in providing certainity and unanimity of approach. Power provided to CBDT * The Board, with the approval of the Central Government may enter into an advance pricing agreement with any person, * (a) determining the arm's length price or specifying the manner in which arm's length price is to be determined, in rela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such APA, shall be determined in accordance with the APA so entered into. The provisions of section 92C or 92A which normally apply for determination of arm's length price will be modified to this extent. As a consequence, arm's length price shall be determined in accordance with APA. [ Section 92CC(3) ] Validity of APA * The APA shall be valid for such previous years as are specified in the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the approval of the Central government, by an order, declare an agreement to be void ab initio, if it finds that the agreement has been obtained by the person by fraud or misrepresentation of facts. [ Section 92CC(7) ] * Consequences - Upon declaring the agreement void ab initio,---- * All the provisions of the Act shall apply to the person as if such agreement had never been entered into; a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the advance pricing agreement. [ Section 92CC(9) ] * Agreement so entered may also be made applicable for international transactions entered into in maximum four preceding previous years [ Section 92CC(9A) ] * Where an application is made by a person for entering into an agreement referred to in section 92CC(1), the proceeding shall be deemed to be pending in the case of the person for the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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